Introduction
Welcome to PersonaCore's privacy policy.
PersonaCore Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we process and look after your personal data when you visit our website (regardless of where you visit it from).
It also tells you about your privacy rights and how the law protects you.
1. Important Information and Who We Are
Purpose of This Privacy Policy
This privacy policy aims to give you information on how PersonaCore Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase any products or services or take part in a prize draw or competition.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
PersonaCore Ltd is the controller and responsible for your personal data (collectively referred to as "PersonaCore", "we", "us" or "our" in this privacy policy).
Contact Details
- Full name of legal entity: PersonaCore Ltd
- Name of data privacy manager: Philip Wigglesworth
- Email address: info@personacore.io
- Postal address: Garden Lodge, 135 Marsland Road, Sale, M33 3NZ
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. The Data We Collect About You
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data: first name, last name, username or similar identifier, and date of birth
- Contact Data: billing address, delivery address, email address and telephone numbers
- Financial Data: bank account and payment card details
- Transaction Data: details about payments to and from you and other details of products and services you have purchased from us
- Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location
- Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Usage Data: information about how you use our website, products and services
- Marketing and Communications Data: your preferences in receiving marketing from us and our third parties
- AI Training Data: personality traits, communication style preferences, content preferences, conversation history with AI twins
- Conversation Data: all messages exchanged between fans and AI twins, conversation topics, sentiment analysis
- Creator Profile Data: detailed personality questionnaires, content style preferences, expertise areas
3. How We Use Your Personal Data
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| To register you as a new customer | Identity, Contact | Performance of a contract with you |
| To create and train AI personality twins | Identity, Creator Profile Data, AI Training Data | Performance of a contract with you |
| To facilitate conversations between fans and AI twins | Conversation Data, Identity, Profile | Performance of a contract with you |
| To process payments | Identity, Contact, Financial, Transaction | Performance of a contract with you |
| To improve AI personality accuracy | Conversation Data, AI Training Data, Usage Data | Legitimate interests (to improve our AI services) |
4. Disclosures of Your Personal Data
We may share your personal data with:
- AI Service Providers: We share Creator Profile Data and Conversation Data with AI service providers (including Anthropic) to train and operate AI personalities
- Payment Processors: We share Financial and Transaction Data with Stripe for payment processing
- Cloud Infrastructure: We use Cloudflare and Supabase for secure data storage and processing
5. International Transfers
We may transfer, store, and process your personal data outside the UK, including to the United States, through our trusted service providers:
- Anthropic (Claude AI): We use Anthropic's API services to power AI conversations. Your Conversation Data may be processed in the United States
- Cloudflare: Our infrastructure uses Cloudflare's global network
- Stripe: Payment processing may involve international data transfers
We ensure all international transfers are protected by appropriate safeguards, including Standard Contractual Clauses.
6. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
7. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for.
- AI Training Data: Retained for as long as the creator account remains active, plus 2 years after account closure
- Conversation Data: Retained for 3 years to maintain conversation context and improve AI performance
- AI Model Data: When you delete your account, we will remove your personal data from active AI models within 30 days
8. Your Legal Rights
Under data protection laws, you have the right to:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing
- Request transfer of your personal data
- Withdraw consent at any time
9. AI-Specific Provisions
How We Use AI
We use artificial intelligence to create digital twins of creators that can interact with fans. This involves:
- Personality Training: Using Creator Profile Data to train AI models to mimic creator personalities
- Conversation Processing: Using Conversation Data to provide realistic interactions
- Continuous Improvement: Analyzing interactions to improve AI accuracy
Your Control Over AI Data
- Creators can update or delete their AI training data at any time
- Fans can delete their conversation history
- Both creators and fans can request export of their AI-related data
AI Limitations
Our AI twins are trained to mimic personalities but are not sentient. They may occasionally produce inaccurate or unexpected responses. We continuously monitor and improve AI performance.
10. UK GDPR Compliance
This Privacy Policy complies with the UK General Data Protection Regulation (UK GDPR) as implemented by the Data Protection Act 2018.
Supervisory Authority: The Information Commissioner's Office (ICO)
- Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
- Telephone: 0303 123 1113
- Website: www.ico.org.uk
11. California Consumer Privacy Act (CCPA)
If you are a California resident, you have specific rights under the CCPA:
- Know what personal information we collect, use, disclose, and sell
- Access your personal information
- Delete your personal information
- Opt-out of the sale of your personal information
- Non-discrimination for exercising your CCPA rights
Do Not Sell My Personal Information: PersonaCore does not sell your personal information to third parties.
12. Canadian Personal Information Protection (PIPEDA)
If you are a Canadian resident, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA).
If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca
Contact Us
For any questions about this privacy policy or to exercise your rights, please contact:
- Email: info@personacore.io
- Address: Garden Lodge, 135 Marsland Road, Sale, M33 3NZ, United Kingdom